IPrivacy policy

The purpose of this Privacy Policy at Enigma Jubiler is to set out comprehensively the measures taken to process and protect personal data collected in connection with the provision of services or the sale of products by

ENIGMA Jubiler
ul. Częstochowska 2
58-100 Świdnica
Tax Identification Number (NIP): 8842656840
Business Registry Number (REGON): 021025110

(hereinafter referred to as “ENIGMA”)

1. The controller of personal data is Enigma Przemysław Jurek, based in Świdnica.
2. The controller selects and applies, with due care, appropriate technical and organisational measures to protect the personal data being processed. The controller protects the personal data of Customers and other individuals whose data has been provided by a Customer against access by unauthorised persons, other disclosure or loss, and unauthorised modification of that data and information.
3. Recipients of personal data include persons acting on behalf of Enigma who are responsible for operating the website in the enigmaonline.pl domain, and entities providing services to Enigma in this respect (e.g. Internet service providers and server hosting providers). Recipients may also include entities entitled to receive the data under applicable law, including the competent judicial authorities.

IIBasis for processing personal data

1. Providing personal data is voluntary; however, failure to provide it may make it difficult or impossible to properly provide a service, complete a sale or provide after-sales support.
2. Personal data is processed on the following grounds:

— the Customer’s acceptance of the terms and conditions of Enigma’s online store,

— the necessity to perform a distance purchase contract for the Customer,

— the controller’s legitimate interest, including defending against claims,

— delivering a purchase to a third party (other than the purchaser), or adapting and developing enigmaonline.pl, including its structure and content, to meet the Customer’s individual needs and maintain the security and quality of the services provided.

1. The controller may process third-party data provided by Customers for communication, referral and use of the controller’s services, including in particular entering into or performing a contract concluded using the tools made available on enigmaonline.pl. By entering such data, the Customer declares that they have obtained the necessary consent from the person whose data they are entering to disclose that person’s data to the controller.
2. Customers’ data may be disclosed to other Customers where this is necessary to perform a contract.

IIIScope and purposes of personal data processing

1. The controller processes personal data in accordance with the law and solely for purposes connected with its business, including entering into and performing sales contracts (handling Product sales transactions, communicating with Customers and dealing with complaints), operating a loyalty programme, and archiving completed services or transactions.
2. Data provided by the Customer is used to send Customers information about Enigma, the controller and its services, to provide the controller’s services, and for statistical purposes.
3. The controller may use IP addresses collected during Internet connections to protect Customers’ interests or establish the facts when dealing with disputes, irregularities or misuse, and for technical purposes related to server administration. IP addresses are also used to collect general statistical information, including information identifying the region from which a connection is made, in order to set the website interface’s default language and tailor marketing content to the Customer’s individual preferences.
4. Personal data is retained for the period necessary to fulfil orders or maintain the Customer’s account at sklep.enigmaonline.pl. After that period, data may be processed on the basis of the controller’s legal obligations (e.g. retention of accounting documents) or legitimate interests (defending against claims that may be brought against the controller).
5. When the Customer uses websites in the enigmaonline.pl domain, computer data (cookies) is stored on the user’s end device (e.g. a desktop computer, laptop, smartphone or tablet).
6. Cookies are used to:

— tailor the content of enigmaonline.pl to the Customer’s individual preferences and optimise use of the website,

— create aggregated statistics to improve the website’s functionality and structure,

— ensure the security of electronically provided services,

— maintain the Website User’s session after logging in,

— make it easier to browse the website’s resources on subsequent visits

1. Cookies do not contain the contact details of users of sklep.enigmaonline.pl
2. Users decide which cookies are stored and how they are stored through their web browser settings (commonly used browsers include Google Chrome, Mozilla Firefox, Internet Explorer, Opera and Safari). Default browser settings allow cookies to be stored.
3. Restricting or blocking cookies may adversely affect certain features available in the enigmaonline.pl domain

IVControl over personal data processing

1. The controller enables individuals whose personal data it processes to exercise their rights under the law, including the rights to access, rectify, amend, erase or transfer their personal data, as well as the rights to request restriction of processing and to object to such processing in accordance with the applicable rules.
2. Where consent to data processing is given voluntarily, every individual whose data is processed has the right to withdraw that consent.
3. Every individual whose data is processed has the right to lodge a complaint with the President of the Polish Personal Data Protection Office.
4. The controller has appointed a Data Protection Officer, who can be contacted about any matter relating to personal data processing by email at: biuro@enigmaonline.pl

VTransfer and disclosure of personal data

1. Customers’ data may be disclosed to entities entitled to receive it under applicable law, including the competent judicial authorities.
2. Personal data may be transferred to Service Providers who perform specific tasks on Enigma’s behalf. These include companies providing:

• technology-related services (e.g. support for Enigmaonline.pl and sklep.enigmaonline.pl),
• payment processing for the online store,
• courier services.

3. Customers’ personal data may be transferred to third parties — in cases not specified by the controller or by law — only with the consent of the person concerned.
4. Personal data may be transferred to third countries (outside the European Union) in connection with deliveries of Products requested by Customers.

VIIVirtual try-on on product pages

On selected product pages of sklep.enigmaonline.pl (signet rings, pendants, bracelets and chains) you can use the virtual try-on: you upload a photo of yourself — your hand, wrist, or face and neckline — and an artificial-intelligence model uses it to prepare an illustrative visualisation of the product on you. The try-on is voluntary and free of charge, and it does not require an account or any contact details.

Data processed: the photo you upload (which may show your image) and the visualisation generated from it. We do not use photos to recognise or identify people.

Purpose and legal basis: preparing the visualisation and keeping it in the shop’s archive for quality control and development of the service — based on your consent (Art. 6(1)(a) GDPR), which you give by ticking the consent box before sending the photo. Without this consent the try-on is not started.

Retention: we do not keep the photo itself — it is deleted from the server as soon as generation starts. The finished visualisation is kept in the shop’s archive for 30 days and then deleted automatically. Together with it we store technical data only: the product, its dimension, the date and time, and the page language — no name, e-mail address or IP address. The working copy of the result, needed to display it in your browser, is deleted right after it is displayed, and no later than after 2 hours. Only the administrator has access to the archive.

Abuse prevention: to prevent abuse, we count the daily number of try-ons made from a single network. For this we use a cryptographic hash of the IP address — the IP address itself is not stored, and the counters are deleted after about 2 days. The legal basis is the administrator’s legitimate interest (Art. 6(1)(f) GDPR) in protecting the service against abuse.

Recipients and transfers outside the EEA: the photo and the visualisation are processed on our behalf by our server infrastructure provider (Netlify, Inc., USA) and by the provider of the image-generation model (OpenAI, USA). Data is transferred to the USA on the basis of the European Commission’s adequacy decision (EU-U.S. Data Privacy Framework) — to the extent the given recipient is covered by it — or of the standard contractual clauses approved by the European Commission.

Your rights: you can withdraw your consent at any time; withdrawal does not affect the lawfulness of processing carried out before it. The archive does not contain your contact details, so if you want a visualisation deleted before the 30 days are up, write to biuro@enigmaonline.pl stating the product and the approximate date and time of the try-on — we will delete it without delay. Your other rights are described in section IV.

Nature of the visualisation: the visualisation is generated by artificial intelligence from the dimensions given in the product description and is for illustration only — it is not an exact representation of the product’s scale or appearance and does not constitute a description of its features.

Analytics: use of the try-on may be recorded in Google Analytics 4 (Google Ireland Ltd.) as events — opening, start, result, download, error — together with the product’s ID and name, on the same terms as other measurements in the shop. We do not send photos, visualisations or contact details there.